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Home My WebLink About01-5956COYNE & COYNE, P.C., Plaintiff VS. DANIELLE E. VAUGHN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O I "a,~__~ CIVIL TERM : · CIVIL ACTION LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against thc claims set forth in the following pages, you must take action within twenty (20) days after this Notice is served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 Liberty Ave. Carlisle, PA 17013 (717) 240-6200 COYNE & COYNE, P.C., Plaintiff VS. DANIELLE E. VAUGHN, Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. ~ CIVIL TERM ; : CIVIL ACTION-LAW COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Coyne & Coyne, P.C. is a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Danielle E. Vanghn is an adult individual residing at 280 Dogwood Drive, Hershey, Dauphin County, Pennsylvania. 3. On or about June 3, 1999, Defendant Vaughn, engaged the Plaintiff for legal services concerning various domestic relations issues to include protection fi.om abuse, support, and divome action and Defendant agreed to pay for services at the rate of $150.00 per hour. 4. Plaintiff performed legal services for Defendant and at the end of said representation submitted an invoice to Defendant for payment. (See Exhibit "A"). 5. Repeated demands for payment in full have been made to Defendant; however, Defendant has refused to pay same. 6. Defendant owes Plaintiff $1,252.31 as balance due and owing with an interest rate of 1.5% per month, annually 18%. 2 WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the mount of $1,252.31, together with Court costs and accruing interest from date from date of complaint filing. Dated: Respectfully submitted, COYNE & COYNE, P.C. L~$A MARIE COYNE~ ESQUIRE ~?01 MaTrkct Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 LAW OFFICES OF COYNE & COYNE, 3901 Market Street Camp Hill PA 17011-4227 Invoice submitted to: Ms. Danielle E. Vaughn 280 Dogwood Drive Hershey PA 17033 October 8, 2001 In Reference To:Domestic Relations Invoice #10310 Interest on overdue balance Total amount of this bill Previous balance Amount $7.83 $7.83 $1,244.48 Balance due $1,252.31 Your account is severly delinquent-- a collection action may be cormmenced-- Please bring your account current EXHIBIT "A" VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A.. § 4904. Dated: SHERIFF'S RETURN CASE NO: 2001-05956 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE P C VS VAUGHN DANIELLE E - OUT OF COUNTY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: VAUGHN DANIELLE E but was unable to locate Her in his bailiwick. deputized the sheriff of DAUPHIN County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On November 2nd , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 30.50 .00 67.50 11/02/200 COYNE & COYNE So answer : ~-. K1 ine Sheriff of Cumberland County Sworn and subscribed to before me this ~ day of ~ A.D. Prot honot'a~y Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AND NOW:October 24, NOTICE & COMPLAINT VAUGHN DANIELLE E to HER of the original : COYNE & COYNE PC vs : VAUGHN DANIELLE E Sheriff's Return No. 3050-T - - -2001 OTHER COUNTY NO. 01-5956 2001 at l:35PMserved the within upon by personally handing 1 true attested copy(ies) NOTICE & COMPLAINT and making known to him/her the contents thereof at 280 DOGWOOD DR. HERSHEY, PA 17033-0000 Sworn and subscribed to before me this 30TH day of OCTOBER, 2001 [ PROTHONOTARY SO Answers, Sheriff's Costs: $30 RCPT NO ~t~ Pa. iff PD 10/24/2001 155745 KLINGER ERVE: In The Court of Common Pleas of Cumberland County, Pennsylvania Coyne & Coyne VS. Danielle E. Vaughn same No. 01 5956 civil NOW, October 17, 2001 ,I, SHERIFF OF CUMBERLAND COUNT'Y, PA, do hereby deputize the Sheriff of Dauphin ' County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland CountY, PA /NOW, within Affidavit of Service ,20 , at o'clock .. M. served the upon at by handing to a and made known to copy ofthe ohgin~ So answers, the contents thereof. Sworn and subscribed before me this .. day of ,2O Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT CountY, PA coYNE & CoYNE, P.C., Plaintiff VS. DANIELLE E. VAUGHN, Defendant : IN THE coURT OF COMMON PLEAS OF : cUMBERLAND couNTY, PENNSYLVANIA : : NO. 01-5956 cIVH, TERM : : CIVIL ACTION - LAW TO: Danielle E. Vaughn 280 Dogwood Drive Hershey, PA 17033 DATE OF NOTICE: August 22, 2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A wRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WiTH THE coURT YoUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT OI~CE' YOU DO NOT HAVE A LAWYER__O. ~1~LEPHOIFNE THE FOLLOWING OFFICE TO FIND DUI wn~r~ ~ ........ T L Cumberland County Lawyer Referral System Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013-3302 1-800-990-9108 Date: August 22, 2003 coYNE & coYNE, P.C. ~[9.~'1 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff cOYNE & COYNE, P.C., Plaintiff VS. DANIELLE E. VAUGHN, Defendant : IN THE COURT OF cOMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA : NO. 01-5956 CML TERM : CIVIL ACTION -. LAW CERTIFICATE OF SERVICE I, Lisa Made Coyne, Esquire, hereby certify that a true copy of Plaintiff's Ten Day Notice of Default was served upon the below-referenced individual by sending the same by first class mail, postage prepaid, addressed as follows: Ms. Danielle E. Vaughn 280 Dogwood Drive Hershey, PA 17033 Dated: